Everything we do at JD is about you! Things change, but it’s nothing to worry about. We take our customers privacy and security very
seriously and we are 100% committed to protecting it so you can shop away
without a single worry. If you have any questions about how we protect your
privacy, just shout us @Privacy.Support@jdplc.com

HOW WE USE YOUR DATA

We are committed to protecting your privacy.It is important that you understand how we
look after your personal data and how we make sure that we meet our legal
obligations to you under the data protection rules and regulations in the
relevant territory (including associated guidance) (the "Data Protection Laws").This
privacy policy outlines how JD Sports Fashion plc and its group companies (together,
the "JD Group") will
collect, use, store and share your personal data.

If you have any questions in relation to this policy or generally how
your personal data is processed by us, please contact our customer care team by
letter addressed to: Topgrade Sportswear
Ltd, 14 Calver Road, Winwick, Warrington, WA2 8UD;
by email at paul.dooley@topgradesportswear.com;
or by phone on 01925 626 838.

This
policy applies to any personal data that we collect about you when you:

·visit our one of our websites;

·purchase products from us;

·visit one of our stores;

·contact us, for example by telephone, email, post or through submitting
a form on our websites.

WHO ARE WE?

In this privacy policy, the terms "we", "our",
and "us" are used to refer
to the JD Group.

The controller of your information for the purposes of the Data
Protection Laws will depend on which member of the JD Group you are dealing
with.The table below sets out each of
the data controllers within the JD Group and each of the brands operated by
those data controllers.

The relevant controller above is responsible for your personal
data.This policy applies to all of the
controllers above and the JD Group as a whole.Our brands each have their own websites.This central policy provides information to you about the basis on which
the JD Group as a whole collects, uses, stores and shares your information. We
will use your personal data fairly, lawfully and in a transparent manner and in
accordance with the Data Protection Laws.

CONSENT

The brands and data controllers listed above within the JD Group may
send you marketing messages by email, SMS, social media and post; about us and
our products; where you have not unsubscribed and where you have purchased
similar products and/or services from that brand or entity, or where you have
otherwise signed up, or consented, to receive marketing messages from a brand
or entity.

You have the right to withdraw your consent to processing of this nature
at any time by contacting our customer care team using the details at the start
of this privacy policy. You can tell us you no longer wish to receive marketing
information from us by viewing your preferences at https://www.topgradesportswear.com/services.asp.

WHAT
INFORMATION DO WE COLLECT ABOUT YOU?

If you have an account with us or make a purchase online with us, or
enter a competition or respond to a survey with us, we collect your name and
contact details (including your address, telephone number, details about your
order, and your billing information (where you are purchasing products)).

We also collect details of your interactions with us through our customer
contact centres, in store, online or via our apps.For example, when you telephone one of our
contact centres, we collect notes of our conversations with you and details of
your query and from time to time we may record your calls for training and
monitoring purposes. We also collect information about the purchases that you
make, your saved items, your payment information, any complaints and comments
that you make and your shopping preferences.We also collect CCTV images in all of our stores.

Each time you visit one of our websites, we will also automatically
collect information and personal data about your computer for system
administration including, where available, your IP address, operating system
and browser type.We do this to help us
analyse how users use the websites (including behaviour patterns and the
tracking of visits across multiple devices), to establish more about our
website users and to assist us in managing your account and improving your
online experience. We also collect
information about your activities on our websites, for example what device you
are using and what products you're looking at.

By way of example, some of our websites use SessionCam
for analysis purposes and specifically to identify any technical issues or
difficulties the users of our websites are having during the customer journey.
To do this, SessionCam records your mouse clicks,
mouse movements, scrolling of pages and the text that you key into forms on our
websites.The information that we collect
about you through SessionCam does not include your
bank details or any special categories of personal data, but does include your name,
address, telephone number, email address and anything else you may insert when
completing an order.The information collected by us through SessionCam is used for our internal purposes only and is
used to improve our websites' usability and is stored and used only for the
purposes of collecting aggregates and statistics relating to the functional
performance of our websites. SessionCam is
operated for the JD Group by SessionCam Ltd.

Please
see our cookies policy for further information about what information may be
automatically collected when you visit our websites.

Cookies Policy

Cookies are small text files that are placed on your
computer by websites that you visit. They are widely used in order to make
websites work, or work more efficiently, as well as to provide information to
the owners of the site.

The table below explains the cookies we use and why.

Cookie

Name

Purpose

More information

Google Analytics

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_utmb
_utmc
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These
cookies are used to collect information about how visitors use our site. We
use the information to compile reports and to help us improve the site. The
cookies collect information in an anonymous form, including the number of
visitors to the site, where visitors have come to the site from and the pages
they visited.

This
cookie is used to record if a user has accepted the use of cookies on the
website.

Navigation

wallp

This cookie is set by the by the web site to control
the menu on the left.

Most
web browsers allow some control of most cookies through the browser settings.
To find out more about cookies, including how to see what cookies have been set
and how to manage and delete them, visit www.allaboutcookies.org.

Please note that, from time to time, we will combine personal data that we
receive from other sources with personal data you give to us and personal data
we collect about you.

WHERE
DO WE GET THIS INFORMATION FROM?

We collect some of your information directly from you, either through
information that you give to us or information that we collect during your
visits to our websites, stores, or through your communications with us.We may also obtain some information from third
parties, including retail analytics companies, consumer insight companies and
credit reference agencies and publicly available sources to assist us with
understanding customer demographics and shopper behaviours, or where we merge with
or otherwise acquire another business.

Information that you give us

You
may share personal data about yourself with us by:

·filling in forms on our
websites, including when you purchase products online, submit queries to us,
create an account on one of our websites and/or sign up to receive
promotional material and newsletters;

·responding to a survey or
entering a competition with us;

·giving us information
about yourself in any communication with us, either by telephone, e-mail,
post or otherwise, either in connection with your account, purchases, or to
report a complaint or issue.

You
are not obliged to provide your personal data to us.However, if you do not provide your
personal data to us, we may not be able to fulfil your order or provide other
services to you or respond to your queries.

Information that we collect about you

We
collect personal data about you:

·when you visit our
websites, including details of your visits to our websites including, but not
limited to, Internet Protocol (IP) address used to connect your computer to
the internet, MAC addresses, traffic data, location data, your login
information, time-zone setting browser type and version, browser plug-in
types and versions, operating system and platform, weblogs, cookies and other
communication data, and the resources that you access. For more information
please see our cookies policy;

·when you link your
Twitter, Instagram or Facebook accounts with us, to enable you to log onto
our websites simply and securely without having to create a new account;

·when you visit one of our
stores, including CCTV images;

·when you contact us in
relation to our products, services, a complaint or another query or
issue.In particular, calls to our
contact centres will be recorded for training and monitoring purposes from
time to time.

Information that we receive from other sources

We
will receive personal data about you from other third parties, including:

·in connection with any
mergers or acquisitions where we obtain your information from another
company.

·When we work with retail
analytics companies, consumer insight companies, credit reference agencies
and through our use of information from publicly available sources.

WHY DO
WE NEED YOUR INFORMATION?

The main purpose for which we use your information is to provide you
with the products that you purchase from us and to send you offers and
promotions that you might be interested in.

In
particular, we use your information:

·to
provide you with the products that you have purchased from us and any receipts
of purchase, including to deliver your products, and to send you order status
updates;

·to
take payments for the products that you have purchased and to give refunds or
exchanges;

·to
provide customer service and support to you;

·to
develop and improve our products and services;

·to
develop and improve our websites and set default options for you (such as
language and currency) and to ensure that content is presented in the most
effective manner;

·to
provide you with information that you request from us or which we feel may
interest you.We may send you marketing
information by email, SMS or post.This
can include information about new products and offers that you may find
interesting;

·to
research our customers' preferences and trending products;

·to run
surveys and competitions;

·to
notify you about changes to our products;

·as
part of our efforts to keep our stores safe and secure (for example through the
use of CCTV in our stores);

·to
prevent and detect fraud and crime (for example, through the use of CCTV in our
stores).

BASIS FOR USING YOUR INFORMATION

Compliance with legal obligations

As a corporate group there are certain laws we need to comply with. In
particular, we will need to process your personal information to verify your identity
and for fraud and crime prevention purposes. Failure to provide the requisite
personal information on sign-up / as you use our websites, may mean we cannot
provide our products to you, as to allow you to purchase our products may mean
we may be in breach of our legal obligations. You will not be able to object to
processing or ask for the deletion of your personal information insofar as it
falls under this category.

Necessary for the entry into or
performance of a contract

When you enter into a transaction with us or one of our brands, a
contract between you and the relevant brand will have been entered into. In
order for us to fulfil our obligations under such contract (e.g. to allow you
to place an order and receive products from us), we will need to collect and
process your personal information. Failure to provide the requisite personal
information on sign-up to an account or on placing an order and payment
information or objecting to this type of processing / exercising your deletion
rights will mean we cannot provide our products to you.

Legitimate business interests

We use
your personal data as set out in this privacy policy for the legitimate
interests of our business to enable us to:

·provide
you with products as requested by you;

·carry
out research to understand our customers and how they purchase and use our
products;

·develop
and improve our products.

As
indicated below, we will also pass your personal data to members of the JD
Group and other third parties and this is also for our legitimate business
interests.

We are required to carry out a balancing test of our legitimate business
interests in using your personal data outlined above against your interests and
rights under the Data Protection Laws and regulations in the relevant
territory.As a result of our balancing
test, which is detailed below, we have determined, acting reasonably and
considering the circumstances, that we are able to process your personal data
in accordance with the Data Protection Laws on the basis that we have a legitimate
business interest.

Legitimate interest

We
have a legitimate interest in processing your information as:

·we both benefit from the
effective management of your account(s) (where applicable);

·we both benefit from the
effective management, operation and administration of our websites;

·we both benefit from the
provision of products, services and support and from improvements to our
services;

·we both benefit from updates
to our websites;

·we will both benefit from
the ability to enforce or apply rights under any contract between us;

·we are required to ensure
the health and safety of our customers and the security of our stored data and
have a legitimate interest in ensuring any processes relating to the same are
effective and that fraud and other crimes are prevented and detected;

·we would be unable to
provide our products and services without processing your information; and

·we have a legitimate
interest in processing your information in connection with any mergers,
acquisitions or reorganisation of our business, in which case some of your
information may be shared with a prospective buyer or otherwise but only so
far as is strictly necessary for the purposes of such sale or administration.

Necessity

We
consider that it is reasonable for us to process your personal data for the
purposes of our legitimate interests outlined above as we process your
personal data only so far as is necessary to achieve the purpose outlined in
this privacy policy.

Impact of processing

We
consider that it is reasonable for us to process your personal data for the
purposes of our legitimate interests outlined above as the processing of your
personal data does not unreasonably intrude on your privacy.

Consent

As set
out above, we will send you marketing communications where you have not told us
that you wish to unsubscribe and where you have purchased similar products and/
or services from the same brand or legal entity (as set out in the table
above). You will also receive marketing communications from us where you have
signed up, or otherwise consented, to receive marketing messages from a brand
or entity within the JD Group.

You
have the right to withdraw your consent to processing of this nature at any
time by contacting our customer care team using the details at the start of
this privacy policy.

WHO DO
WE SHARE YOUR INFORMATION WITH?

We do
not, and will not, sell any of your information to any third party, including
your name, address, email address or credit card information.However, we do share your information with a
number of select third parties to enable us to provide our products and
services to you, to send marketing information and to improve our business
operations as set out below.

We will
share your information with other members of the JD Group but only for the
purposes specified in this privacy policy.In particular:

·we will
share your information with other members of the JD Group where you have
consented for us to do so for the purposes of receiving marketing from those
other JD Group members;

·we
will share your information with other members of the JD Group for group
analysis and business information purposes, to improve our products and
services.

We will also use a number of carefully selected third parties to help us
to provide you with products, services and to market to you. In particular, we disclose
your information to:

·Companies
that do things to get your purchases to you, such as payment service providers,
warehouses, order packers and delivery companies;

·Our
trusted service providers, such as marketing agencies, advertising
partners, website hosts and other third parties who provide services to help us
to tailor our marketing to you;

·Companies
approved by you, such as social media sites, including companies such as
Facebook and Google; and

·We will
provide third parties with aggregated but anonymised information and analytics
about our customers and, before we do so, we will make sure that it does not
identify you.

We will only share your information with third party suppliers where it
is necessary for them to provide us with the services we need.

We may disclose your information to other companies in connection with
any merger, acquisition, insolvency situation or otherwise, in which case we
will only disclose your information so far as is necessary.

We may also need to disclose personal data to third parties to comply
with a legal or regulatory obligation, or if necessary for legal proceedings.

WHAT AUTOMATED
DECISIONS DO WE MAKE ABOUT YOU?

We
carry out some profiling of you for the purposes of improving and developing
our products and services and to help us to tailor our marketing to you.

The impact of any automated decision is to ensure you experience the
best service possible.

We use information that we learn about you such as your gender,
preferences, hobbies, interests and purchase history to make sure the marketing
you receive from us and the way our websites are displayed to you are appropriate
and tailored to you.

WHERE
IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?

Transfers
outside of the European Economic Area

The
information which we collect about you may be transferred outside the European
Economic Area. In the event of such transfer, we will ensure the adequate
standard of security is in place for example by incorporating the European
Commission approved clauses into our agreements with such third parties to
ensure the security of your personal data.A copy of the European Commission approved model clauses is available
here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en

Retention
of your personal data

We will only keep your information for as long as is necessary to carry
out the purposes we collected it for, as set out in this privacy policy (unless
a longer retention period is required by the applicable law).We typically keep your personal data for 6 years from the purchase in order to
enable us to deal with any issues or concerns you may have about the products
or services you have received, and to allow us to bring or defend legal
proceedings.In some circumstances, some
of your data will be deleted in much shorter timescales, for example:

·cookies
are deleted in accordance with our cookies policy;

·CCTV
images are kept for 60 days;

·marketing
consents will be refreshed/deleted after 4 years, however, our aim is only to
market to you for as long as we believe you want to continue hearing from us
based on how you interact with us.

If
reasonably necessary or required to meet legal or regulatory requirements,
resolve disputes, prevent fraud and abuse, or enforce our terms and conditions,
we will also keep hold of some of your information, even if it is no longer
needed to provide our services to you.

Security
of your personal data

Transmission of information via the internet is not and cannot be
completely secure. Although we will do our best to protect your personal data,
we cannot guarantee the security of your data transmitted to our websites; any
transmission is at your own risk.Once
we have received your information, we will use strict procedures and security
features to try to prevent unauthorised access.

WHAT
NON-PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT?

We may also collect non-personally identifiable information (that is,
information that does not specifically identify you), for the purposes of aggregates
and statistics.

WHAT
RIGHTS DO YOU HAVE?

You
have a number of rights under the Data Protection Laws in relation to the way
we process your personal data, which are set out below.You may contact us using the details at the
beginning of this privacy policy to exercise any of these rights.

In
some instances, we may be unable to carry out your request, in which case we
will contact you to explain why.

1. You have the right to request access to your personal data

You
have the right to request confirmation that your personal data is being
processed, access to your personal data (through us providing a copy) and
other information about how we process your personal data.

2.You have the right to
ask us to rectify your personal data

You
have the right to request that we rectify your personal data if it is not
accurate or not complete.

3.You have the right to
ask us to erase your personal data

You
have the right to ask us to erase or delete your personal data where there is
no reason for us to continue to process your personal data. This right would
apply if we no longer need to use your personal data to provide products to
you, where you withdraw your consent for us to send you marketing information,
or where you object to the way we process your personal data (see right 6
below).

4.You have the right to
ask us to restrict or block the processing of your personal data

You
have the right to ask us to restrict or to block the processing of your
personal data that we hold about you.This right applies where you believe the personal data is not accurate,
you would rather we block the processing of your personal data rather than
erase your personal data, where we don't need to use your personal data for
the purpose we collected it for but you may require it to establish, exercise
or defend legal claims.

5.You have the right to
port your personal data

You
have the right to obtain and reuse your personal data from us to reuse for
your own purposes across different services.This allows you to move personal data easily to another organisation,
or to request us to do this for you.

6.You have the right to
object to our processing of your personal data

You
have the right to object to our processing of your personal data on the basis
of our legitimate business interests, unless we are able to demonstrate that,
on balance, our legitimate interests override your rights or we need to
continue processing your personal data for the establishment, exercise or
defence of legal claims.

7.You have the right not
to be subject to automated decisions

You
have the right to object to any automated decision making, including
profiling, where the decision has a legal or significant impact on you.

8.You have the right to
withdraw your consent

You
have the right to withdraw your consent where we are relying on it to use
your personal data, for example where we are relying on your consent to send
you marketing information.

Marketing

We always give you the choice of whether or not you wish to receive marketing
communications from us.

By contacting us Privacy.Support@jdplc.comyou
can tell us that you do not wish to receive marketing communications from us
and we will update your records. You can also click on the unsubscribe link in
any promotional emails.

WHAT
IF YOU HAVE A COMPLAINT?

If you
have any concerns regarding our processing of your personal data, or are not
satisfied with our handing of any request made by you, or would otherwise like
to make a complaint, please contact our customer contact centre in the first
instance using the details at the start of this privacy policy, so that they
can do their very best to sort out the problem.

You
can also contact the Information Commissioner's Office at Wycliffe House, Water
Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk.

OTHER
WEBSITES

Our
websites may, from time to time, contain links to and from the websites of
third parties. If you follow a link to any of these websites, please note
that these websites have their own privacy policies and that we do not accept
any responsibility or liability for these policies or your use of those
websites.

CHANGES
TO THIS PRIVACY POLICY

We
will take all measures necessary to communicate any changes to this privacy
policy to you, and will post any updated privacy policies on this page.